United States Office of Pollution Prevention EPA742-R-97-003

Environmental Protection and Toxics (MC7409) May 1997

Agency Washington, DC 20460

Applying Environmental

Accounting to Electroplating

Operations: An In-Depth

Analysis
DISCLAIMER

Throughout this report, interpretations and analysis are provided on research findings

generated through this project. This analysis and the accompanying conclusions should

not be interpreted as representative of environmental accounting applications in other

industries. Moreover, the findings and conclusions are based on a small sample of metal

finishing operations visited in conjunction with this project and other WRITAR projects.

Although WRITAR believes that many of the issues discussed in this report are generally

representative of metal finishing operations, we recognize many of the barriers and

contextual issues may not apply to individual facilities. As a result the issues concerning

adoption of environmental accounting practices should not be extrapolated to the entire

industry.

This report is intended for an audience with a basic understanding of environmental

accounting concepts and metal finishing operations. For introductory or additional

information on environmental accounting, or for more copies of this document, please

call the Pollution Prevention Information Clearinghouse at (202) 260-1023 or visit the

EPA’s Environmental Accounting Project Web Site at:

http://www.epa.gov/opptintr/acctg
ACKNOWLEDGMENTS

WRITAR wishes to thank the many facility representatives who generously shared their

time and facility operations with us to better understand the issues and practical

implications of implementing environmental accounting. A special thanks is also given

to the following individuals and institutions who have provided review and comments on

this report:

Frank Altmayer

President, Scientific Control Laboratories, Incorporated

John F. Cross

Deputy Director, Pollution Prevention Division

Office of Pollution Prevention and Toxics

Environmental Protection Agency

Susan McLaughlin

Co-Manager, Environmental Accounting Project, Pollution Prevention Division

Office of Pollution Prevention and Toxics

Environmental Protection Agency

Tom Murray

Chief, Prevention Analysis Branch, Pollution Prevention Division

Office of Pollution Prevention and Toxics

Environmental Protection Agency

Robert Pojasek

Senior Program Director

Cambridge Environmental Incorporated

Lisa Regenstein

Common Sense Initiative Metal Finishing Sector

Northeast Waste Management Officials’ Association

Karen Shapiro

Associate Scientist, Risk Analysis Group

Tellus Institute

William Sonntag

Legislative Director

National Association for Metal Finishers

Martin Spitzer

Executive Director

President’s Council on Sustainable Development
Jordan Spooner

Common Sense Initiative Metal Finishing Sector

Office of Enforcement and Compliance Assurance

Environmental Protection Agency

Scott Throwe

Common Sense Initiative Metal Finishing Sector

Office of Enforcement and Compliance Assistance

Environmental Protection Agency

Allen White

Director, Risk Analysis Group

Tellus Institute
U.S. Environmental Protection Agency

Environmental Accounting Project

This paper was prepared by the Waste Reduction Institute for Training and Applications

Research (WRITAR) under cooperative agreement # 821434-01-0 for the U.S. EPA

Environmental Accounting Project. The EPA Project Officers were Holly Elwood and

Marty Spitzer. WRITAR staff responsible for this research were Mark Haveman and

Terry Foecke.
TABLE OF CONTENTS

Title Page

Disclaimer

Acknowledgments

Executive Summary 1

1.0 Purpose of this Document 4

2.0 Definition of Cost Terms Used in this Document 7

3.0 Background on Research Strategy and Implementation 9

4.0 Analysis of Environmental Costs in Electroplating Operations 16

4.1 Materials 16

4.2 Waste Management 24

4.3 Utilities 26

4.4 Direct Labor 28

4.5 Indirect Labor 29

4.6 Regulatory Compliance 30

4.7 Incremental Revenues 32

5.0 Issues in Implementing EA in Electroplating Operations 33

5.1 Identifying Environmental Costs 33

5.2 Prioritizing Costs to Investigate 35

5.3 Quantifying or Qualifying Costs 36

5.4 Allocating Costs to Products or Processes 39

5.5 Integrating Costs into Decision-Making 42

6.0 Guidance for Investigating Lost Material Costs in Electroplating 48

Project Bibliography
1

EXECUTIVE SUMMARY

This report presents research findings regarding the implementation of environmental

accounting (EA) practices in the electroplating industry, conclusions regarding the

potential for its wider adoption and use, and recommendations for investigating

environmental cost structures in this industry. The research entailed 24 on-site

investigations into both captive operations (electroplating included as part of a larger

manufacturing process), and job shop facilities (specializing in providing electroplating

services to manufacturers), and extensive literature reviews on electroplating costing

practices and EA analysis. This report focuses on electroplating operations, and any

references in this report to "metal finishing" pertains exclusively to electroplating

operations.

Following are the primary research findings:

1. Many of the facilities visited are already using parts of EA without knowing or calling

it that. Most "conventional" costs (e.g. wastewater treatment operations, hazardous waste

disposal) associated with environmental management are recognized and captured in new

project or process evaluations.

2. EA was found to have potential for elucidating "hidden" costs and creating a more

robust and accurate economic evaluation of projects.

3. As can be expected, the five environmental costs of greatest significance to

electroplating facilities are wastewater treatment (and its many individual cost

components), hazardous waste disposal, sewerage, plating chemistry loss, and other

process solution loss.

4. The cost issues most frequently found to be significant and underrecognized in facility

decision-making situations are the chemistry and solution losses. These cost areas are

especially appropriate for more in-depth analysis because of 1) the repercussions they

have elsewhere in the facility's environmental management cost structure; and 2) its

potential implications in highlighting the "true" cost of facility waste beyond disposal and

wastewater treatment. However, these costs are more challenging to derive since they are
2

not hidden in overhead accounts, but must be assembled through materials balances and

an examination of production records.

5. Environmental costs of all types can be quantified, but cost/benefit implications of

gathering this information depends on facility needs and circumstances.

6. Environmental management costs which did not directly affect payroll and payables

(e.g. labor costs of preparing a TRI report or manifesting) had often been left out of

project evaluations, but in revisiting projects facilities found them useful to consider and

quantify. However, metal finishers demonstrated some hesitancy to formally factor them

into an actual economic evaluation of a project. Electroplating facilities were strongly

oriented toward using conservative and reliable cost estimates in decision-making and

factoring in only those issues directly impacting cash flow.

7. One of the most valuable uses and applications of EA in electroplating was found to

be in generating greater facility interest in exploring process understanding and control

issues. Applying environmental accounting suggested that three types of activities are

typically undervalued in facility operations:

• Episodic activities -- such as disposal of tank bottoms, bath dumps, filter

replacement, and decommissioning of process lines. Applying environmental

accounting to these activities demonstrates a more powerful economic rationale to

invest in process control and reexamine ways to reduce these episodic events.

• Rework activities -- which creates new types of wastes and unnecessary

additional discharges. Because of underrecognized environmental cost

implications, the facility's cost of quality is typically low. Full environmental

costing of rejects creates a more powerful economic rationale to take a quality

improvement approach which also prevents pollution.

• Rinsing activities -- the difference between what is technically needed to rinse

sufficiently and what the facility is actually using. Every gallon of excess water

use created an environmental cost that typically was found to be undervalued and

underrecognized.
3

EA analysis can be used to fully cost these issues and in so doing demonstrate cost saving

potential through pollution prevention activities which are far greater than originally

anticipated.

8. Gathering and tracking information for certain types of environmental costs poses a

potential obstacle since "mining" this information at a level of detail necessary for it to be

allocated to the responsible processes may be an expensive thing for a facility to do.

Without other opportunities for using this information, its collection and management

may not be practical for a facility.

9. Allocating costs to processes responsible for generation is the largest barrier to greater

EA adoption in electroplating. The amount of variation inherent in finishing, the

systemic nature of finishing with complex cause and effect relationships, and the number

of factors and episodic events affecting performance makes allocation quite challenging.

Allocation based on actual contribution is outside the realm of possibility for most

facilities, allocations based on estimated calculations requires some technical analysis,

and allocations based on best professional judgment can be dramatically different from

reality. Allocations based on an appropriate production factor (square feet processed,

hours of operation, etc.) is perhaps the simplest type of estimated calculation applicable

to many types of environmental costs.

10. EA can be a valuable tool to target facility improvement areas when used in conjunction

with other targeting methods such as reject rate analysis. Targeting improvement areas based

solely on relative contributions to facility environmental management overhead demonstrated a

tendency to redirect facility attention from where the greatest gains could be realized.
4

1.0 PURPOSE OF THIS DOCUMENT

This document contains the findings and results of an 18 month investigation on the

application of environmental accounting practices in electroplating facilities. The

purpose of this research was to conduct a detailed examination of the mechanics of

implementing EA practices within a specific industry.

Environmental accounting has been defined as "the addition of environmental cost

information into existing cost accounting procedures and/or recognizing embedded

environmental costs and allocating them to appropriate products or processes” (ICF Inc.,

1995). As a powerful decision-making tool, environmental accounting practices are

being widely promoted throughout all types of industry. Many companies have realized

decision-making benefits from an adoption of this methodology and a higher quality

understanding of their overall cost structures. Specifically, EA offers two primary

advantages:

1) Capital budgeting decisions -- Misallocations and failure to factor in changes in

cash flow expenditures pertaining to environmental management can affect the economic

justification of environmentally preferable process or technology alternatives. The use

of EA approaches to create a more robust and accurate economic analysis of capital

projects is one of the primary benefits of EA adoption.

2) Targeting of improvements -- A related benefit to manufacturers is the use of

EA methods to target and prioritize areas of improvement. Through EA analysis, a

facility can rank order its waste streams based on contributions to facility environmental

costs and prioritize pollution prevention efforts to target those areas which contribute the

most to direct and indirect environmental management expenditures and generate the

greatest cost savings to the facility.

While the advantages and benefits of EA are well documented, some of the issues in

actually implementing an EA investigation may be less understood. In this research

study, WRITAR examined moving from concept to practice by examining a variety of

implementation issues pertaining to EA adoption in electroplating operations. Relevant

issues studied included:
5

• the types of data gathering and management activities needed to support EA 

analysis in electroplating operations

• the infrastructure needed to support EA investigations on an ongoing basis

• an examination of the "value added" to be gained in decision-making and

targeting through such an analysis; i.e. will the benefits of EA outweigh the

costs to the firm?

The electroplating industry was chosen to be the focus for two reasons: the majority of

metal finishers are small businesses with limited resources for conducting this kind of

research on their own, and the fact that environmental benefits could be gained if metal

finishers and those who work with metal finishers could access new information on a tool

to improve environmental performance. The purpose of this document is to report the

findings of the research and to provide guidance for metal finishers, assistance providers,

and other professionals on implementing EA in this industry.

 This project is part of a larger effort being sponsored by the EPA on environmental

accounting methods. The goal of the EPA's Environmental accounting Project is to

encourage and motivate businesses to understand the full spectrum of environmental

costs and to incorporate those costs into decision-making. The objectives of this

overarching initiative as defined by EPA's stakeholders are:

• to create better definitions of key terms and concepts;

• to create management incentives to upgrade managerial accounting practices; 

• to conduct education, guidance, and outreach programs; and,

• to develop and disseminate analytical tools, methods, and systems.

The research contained in this report is meant to support these objectives by providing

information on the application of environmental accounting methods within an industry

of special interest. Electroplating/electroplating operations are a target industry for

several environmental policy development and pollution prevention outreach efforts

including the EPA Design for the Environment Program and the Common Sense

Initiative. This research effort has worked in collaboration with these other electroplating

initiatives and expands upon these efforts.

The report is broken into three primary parts. Section 2.0 provides additional background

information on the research activities and method used for this project. Section 3.0
6

describes the research findings and an analysis of environmental management costs in

electroplating facilities. Section 4.0 examines EA implementation issues in light of

production and management realities of electroplating operations. Finally, section 5.0

presents strategy and recommendations for those interested in investigating electroplating

cost structures and identifying areas of improvement.

This report assumes both a basic knowledge of electroplating processes and a basic

understanding of environmental accounting methodology. For additional information on

the basics of electroplating and associated environmental issues, readers are encouraged

to review Profile of the Electroplating Industry available from the Cleveland Advanced

Manufacturing Program, Cleveland, OH. For more information on EA, call the Pollution

Prevention Information Clearinghouse at (202) 260-1023 and ask for an introductory

packet on EA to be sent to you. Or visit the EPA Environmental Accounting website at:

http://es.inel.gov/partners/acctg
7

2.0 DEFINITIONS OF COST TERMS USED IN THIS DOCUMENT

As noted in the U.S. EPA publication, "An Introduction to Environmental Accounting as

a Business Management Tool: Key Concepts and Terms," there are many different

classifications and typologies of costs. The following is a glossary of terms for readers of

this document. While we have tried to be as faithful as possible to generally accepted

definitions found in this EPA publication as well as other documents, slight variations

may exist in an effort to try an convey the cost issues associated with electroplating more

clearly.

Environmental Accounting -- the identification, prioritization, quantification or

qualification, and incorporation of environmental costs into business decisions.

Environmental Costs -- A general classification for several types of costs relating to the

use, release, and regulation of materials in facility operations. For purposes of this report,

it is comprised of environmental management costs, opportunity costs, contingent costs,

and image costs.

Environmental Management Costs -- All expenditures directly associated with the

environmental management function of the facility and in keeping a facility in regulatory

compliance.

Opportunity Costs -- Lost value of process solution/chemistry and other lost material

costs associated with unoptimal use of raw materials in facility operations

Contingent Costs -- Environmental costs that are not certain to occur in the future but

depend on uncertain events. Sometimes referred to as liability costs or contingent

liabilities. Not examined in this report.

Image Costs -- Less tangible costs incurred to affect subjective perceptions of

management, customers, employees, communities, and regulators. Also know as

relationship costs. Not examined in this report.
8

Conventional Costs -- Costs typically recognized in capital budgeting exercises and

financial analyses of projects. Also known as usual costs.

Hidden Costs -- Environmental costs that may be potentially unrecognized by managers

because of their infrequent/episodic nature and/or because of their collection in company

overhead accounts.

Operating Costs -- Costs incurred through operating a process, system, or facility. The

primary focus for this document.

Direct Costs -- Costs clearly and exclusively associated with a product or service and

treated as such in cost accounting systems.

Indirect Costs -- All costs that are not accounted for as the direct costs of a particular

process, system, product, of facility. Commonly pooled and allocated on the basis of

some formula or are not allocated at all.
9

3.0 BACKGROUND ON RESEARCH STRATEGY AND IMPLEMENTATION

The project commenced with a literature review of a number of standard texts on job

costing, manufacturing accounting, and activity based costing looking for relevant

insights on cost tracking. A subsequent literature search identified articles pertaining to

best practices in job costing and manufacturing accounting in electroplating operations.

Primary resources are listed in the bibliography of this report.

With this background information in place, a number of interviews were conducted with

leading experts in the field of electroplating to explore issues pertaining to the

applicability and value-added of EA adoption. References were obtained from these

experts for potential contacts of facilities which have attempted or implemented EA based

analyses.

An interview strategy was designed and tested among representatives of electroplating

firms with which WRITAR has a close association. Exhibit 1 is a basic outline of the

research protocol. After obtaining basic background information on business trends and

issues, process descriptions with supporting information on materials uses and releases

were gathered. Examples were then reviewed of past process improvement / technology

change efforts at the facility to review how the facilities examined costs in the past.

With the cooperation of the facility representatives, WRITAR then embarked on an

investigation of EA application issues pertaining to electroplating operations. The

investigation centered on hexavalent chrome processes and zinc cyanide processes -- both

of which are under regulatory pressure and are common targets for change, and therefore

likely opportunities for using EA analysis. Project researchers used an environmental

cost category template developed by the Tellus Institute1 as the analytical framework for

the investigation (See Exhibit 2). In examining the various labor, materials and overhead

cost elements, four questions comprised the focus of this portion of the research.

1. What is the applicability of these costs to electroplating?

2. How are they currently allocated and how likely could they be allocated or 

processes or parts?

 1 As adapted and reported in "Improving Your Competitive Position: Strategic and Financial Assessment of

Pollution Prevention Projects" NEWMOA, 1994
10

3. What is the significance of various types of costs to electroplating?

4. If an assignment is made, would it be accurate?

Reviewing for applicability involved identifying which cost elements were relevant to

electroplating operations and obtaining a better understanding of how they were relevant.

Reviewing for allocation involved exploring how the facility currently accounted for

these costs and assessing their ability to assign or allocate those costs to responsible

products or processes to support decision-making. This review enabled researchers to

gain an understanding of how environmental costs are currently handled, how they might

be managed differently, and how to transition from a conventional cost analysis to an

analysis based on EA.

The final two questions were investigated to better understand the practical implications

of using EA in electroplating operations. WRITAR considered cost significance to be an

important qualifying issue in adopting EA methods. It was assumed that establishing a

threshold of significance helped ensure that the likely benefits of using this cost

information for decision-making purposes would be greater than the costs of gathering

and analyzing this information. For purposes of this report, .5% of gross annual

revenues was selected as a "significance threshold." This was based on previous

WRITAR experiences in working with metal finishers which indicated that cost issues of

this magnitude are most likely to get the attention and interest of facility management.

"Environmental management" costs in aggregate well-exceeded the significance

threshold; 6% - 12% was a common range found in the course of the research2 . Within

this collection of costs, particular emphasis was placed on reviewing and analyzing those

elements exceeding the .5% criteria.

Allocation accuracy was chosen as another critical issue to help ensure against situations

in which the value of EA analysis might be rendered moot by inappropriate relationships

between various activities and elements of cost. It is evident that facilities often must

estimate, use best professional judgment, or a combination of both practices to assign

many environmental costs to processes. The research placed an emphasis on identifying

circumstances in which the accuracy of allocation efforts would likely be low because it

was presumed that inaccurate allocations could potentially mislead or misdirect facility

decision making.

 2 This range was based on a consideration of all labor, materials, and other expenditures directly associated

with environmental management activities and keeping a facility in compliance.
11

Throughout this report, qualifiers are used to describe facility conditions and practices.

Cost definitions are found in the report appendix. Following are other definitions used by

the project researchers during the course of the investigation and found in this report.

• Allocated by product -- cost is used as a line item for calculating a unit price for

finishing a specific part or type of part

• Allocated by process -- cost is used to calculate the contribution of a unit operation to

facility costs and/or unit price for a specific part or type of part.

• "Accurate" -- data from purchase records or similar; auditable

• "Mostly accurate" -- data from purchase records or similar, subdivided based on number

of operations, number of tanks, number of parts produced, etc. and verifiable by

production records

• "Somewhat accurate" -- based on data from production records and logs; values are

obtained by multiplying volumes by cost data and should balance over long periods of

times with purchase records.

WRITAR benefited from having the opportunity to tie this investigation into several

concurrent projects being pursued with the electroplating industry. As a result, a total of

24 shops were visited ranging from small job shops to captive specialty plating operations

in the aerospace industry. Of these, six were contacted and visited specifically under the

auspices of this project. The remaining 18 sites were visited for other project purposes

but were interviewed based on the protocol or sections of the protocol. In addition,

another 20 telephone interviews were held with various facility representatives and

experts pertaining to selected issues contained in the protocol. Interviews were held with

environmental, accounting, production/quality, and inventory managers. Exhibit 3

provides a description of the types of facilities visited.
12

Exhibit 1 -- Research Protocol

Company Background

a. Products

b. Facility Descriptors

c. Notable trends

e. Corporate P2 program status

f. Competition analysis

h. Drivers for P2 and EA -- Regulations, Economics, Competition

Past Process Change Efforts

a. Process improvement --associated cost analysis

b. Pollution prevention --associated cost analysis

Process Descriptions

a. Input - output

b. Process flow (simple block diagram)

c. Specifics for zinc cyanide and/or hexavalent chrome (decorative)

1. Waste volumes for 1994 and 1995, est. 1996

2 Material use volumes for 1994 and 1995, est. 1996

3. Production volume

4. Recent changes; planned changes

d. Specifics for support processes

Costing

a. Operating regulatory costs

b. Materials costs

c. Allocation procedures / relation to pricing

d. Analysis of information quality
13

Exhibit 2 Potential Operating Costs Included in an EA Analysis

Materials Regulatory Compliance

direct product materials monitoring

catalysts and solvents manifesting

wasted raw materials reporting

transport notification

storage recordkeeping

training (right-to-know, safety, etc.)

Waste Management (Materials &

Labor)

training materials

pre-treatment inspections

on-site handling protective equipment

storage labeling

hauling penalties / fines

insurance lab fees

disposal insurance

R&D to comply with regulations

Utilities handling (raw materials and waste)

electricity closure & post-closure care

steam

cooling & process water Revenues

refrigeration sale of product

fuel (gas or oil) marketable by-product

plant air & inert gas manufacturing through-put change

sewerage change in sales from:

 increased market share

Direct Labor improved corporate image

operating labor & supervision

manufacturing clerical labor

inspection (QA & QC)

worker productivity changes

Indirect Labor

maintenance (materials & labor)

miscellaneous (housekeeping)

medical surveillance
14

Exhibit 3 Descriptions of Visited Electroplating Operations

NUMBER OF EMPLOYEES INDUSTRY SERVED PROCESSES

(MINOR PROCESSES)

CAPTIVE (C)

JOB SHOP (JS)

20 production1

2 maintenance2

0 direct administrative3

0 direct sales

Tubular steel; furniture and

displays

Copper/nickel/chrome

(phosphating)

(C)

20 production

0 direct maintenance

3 administrative

1 sales

Tubular steel; furniture and

displays; exercise equipment

Copper/nickel/chrome

(bright nickel)

(black nickel)

(JS)

6 production

1 maintenance

2 administrative

0 direct sales

Tubular steel; furniture and

displays

Copper/nickel/chrome (JS)

20 production

2 maintenance

2 administrative

0 direct sales

Cast, forged steel; hand tools

and related equipment

Copper/nickel/chrome

(phosphating)

(anodizing)

(C)

32 production

3 maintenance

5 administrative

2 sales

Cast, forged steel; hand tools

and related equipment

Copper/nickel/chrome (JS)

14 production4

2 maintenance

5 administrative5

0 direct sales

Formed sheet steel; bumpers

and auto trim; new and rework

Copper/nickel/chrome (JS)

120 production

10 maintenance

20 administrative

5 sales

Formed sheet steel; bumpers

and auto trim; new

Copper/nickel/chrome (JS)

45 production

5 maintenance

7 administrative

2 sales

Injection-molded plastic;

nameplates and trim

Copper/nickel/chrome

(gold)

(JS)

100 production

8 maintenance

0 direct administrative

0 direct sales

Cast brass; sanitary fixtures Copper/nickel/chrome

(bright nickel)

(electroless nickel)

(tin/lead solder)

(C)

75 production

12 maintenance

12 administrative

4 sales

Injection-molded plastic;

sanitary fixtures

Copper/nickel/chrome

(black chrome)

(JS)

32 production

6 maintenance

7 administrative

2 sales

Sheet steel, fabricated;

electronics; housings and

enclosures

Zinc and chromate

(powder coating)

(JS)

 1Calculated as full-time equivalents

2Includes environmental

3 "Direct" refers to a position devoted to this activity in this area (in the case of captive shops) or facility (in the case of

job shops. The activity, if listed as "0", is covered as part of another position.

4Includes stripping and buffing operations

5Includes counter sales
15

12 production6

0 direct maintenance

2 administrative

0 direct sales

Sheet steel, fabricated;

electronics; housings and

enclosures

Zinc and chromate

(painting)

(JS)

6 production

0 direct maintenance

1 administrative

0 direct sales

Ferrous and non-ferrous

machined parts; consumer

goods; fasteners

Zinc and chromate

(silver)

(copper)

(JS)

38 production

4 maintenance

7 administrative

1 sales

Variety of substrates and

forms; consumer goods;

fasteners

Zinc and chromate

(tin)

(tin lead)

(JS)

24 production

2 maintenance

3 administrative

0 direct sales

Wide variety; no primary

market

Zinc and chromate (JS)

18 production

2 maintenance

4 administrative

1 sales

Wide variety; no primary

market

Zinc and chromate (JS)

607 production

2 maintenance

3 administrative

1 sales

Steel enclosures and parts;

military

Zinc and chromate (JS)

5 production

0 direct maintenance

3 administrative

0 direct sales

Specialty; electronics Zinc and chromate

(precious metals)

(anodizing)

(C)

20 production

2 maintenance

3 administrative

1 sales

Wide variety; no primary

market

Electroless nickel (JS)

12 production

2 maintenance

2 administrative

0 direct sales

Wide variety; no primary

market

Electroless nickel (JS)

6 production

0 direct maintenance

3 administrative

0 direct sales

Specialty; electronics Precious metals (JS)

49 production

4 maintenance

9 administrative

3 sales

Ferrous and nonferrous

substrates; jewelry

Precious metals (C)

14 production

2 maintenance

0 direct administrative

0 direct sales

Steel; printing Hard chrome (C)

8 production

0 direct maintenance

0 direct administrative

0 direct sales

Steel and other substrates;

automotive

Hard chrome (C)

 6Other areas not involved in metal finishing not included

7Includes specialty cleaning operation
16

4.0. ANALYSIS OF ENVIRONMENTAL COSTS IN ELECTROPLATING 

OPERATIONS

Exhibits 4-7 summarize the research findings on cost issues found in electroplating

operations. The research focused exclusively on operating costs -- both direct and

indirect. Contingent costs (costs based on probabilities of events occurring in the future)

and image costs ( intangible costs associated with company goodwill of improving

environmental performance) were not included as part of the investigation. The rationale

for their omission is that these costs are highly context and situation specific while the

purpose of this report was to generate information generally applicable to all

electroplating facilities.

The following synopses of operating costs is based on the cost categories found in

Exhibit 2. During the analysis, special attention was given to cost elements which other

EA research studies had found to be frequently under recognized in operations in order to

shed additional light and information on identifying, quantifying, and allocating these

costs.

 Following are synopses of each cost area.

4.1 Materials 

Key wasted materials costs in electroplating

• Process chemistry • Water

• Addition agents • Miscellaneous chemistries (e.g.strippers, chromates)

• Cleaners • Acids

Direct Product Materials -- Applicability and Significance

Costs for coating materials (zinc, nickel, copper, gold, silver, etc.) appear to vary greatly

both comparatively and with respect to their significance in the overall facility cost

structure. Precious metals and some other materials (like electroless nickel, electroless

copper, and some alloys) are expensive to deposit. Significance is also affected by the

scope of processes within a shop -- if a facility focuses on a particular type of plating
17

process, plating materials associated with this process will be a large item for the facility

even if the materials are comparatively inexpensive. Hidden costs in terms of materials

waste can be traced to two sources - a differential between the amount of coating

materials purchased and the amount of metal that actually goes out on parts, and another

differential between the amount of metal that goes out on parts and the amount that is

actually needed to meet the desired production requirements. This, of course, has

subsequent implications for wastewater and disposal costs.

Costs for addition agents (brighteners; pH adjustment; consumable components like

cyanide) demonstrate enormous variation by process, and are dependent not just on

market price of metals (as in the cost of coating materials), but also on the cost of

formulation, size of market (small niches may feature high materials prices enabling

manufacturers to recoup development costs), age of product (new materials cost more)

and function of the process solution (run to depletion like electroless nickel vs. maintain

for many years like nickel sulfate). The research suggests that by far the most ubiquitous

and expensive (cost per unit volume as well as total cost) are brighteners. Research also

suggested that cost understanding is often poor in this area as standard operating practices

for additions is often highly subjective. As a result, a scan for price and use volumes is

highly recommended in reviewing plating cost structures.

As with other direct materials inputs, costs for acceptable water vary greatly, and will

depend on the type of process solution and products. Water inputs can be characterized

most readily in reference to either 1) current water quality (usually most important when

using ground water rather than drinking water) and/or 2) market niche (electronics

requiring extremely pure water, most others increasingly requiring at least supplemental

treatment up to and including deionization). Also influencing the variability and relative

significance of water costs are noted trends toward generally higher water costs and, in

some cases, restricted availability (South San Francisco Bay Area; Phoenix; Los Angeles

County). Water costs are also linked to pretreatment costs, since capital costs for

equipment are directly linked to hydraulic loadings of the system. This, in turn,

establishes a relationship with other cost issues such as indirect labor since the greater the

hydraulic loading, the larger the system, and the more maintenance is required. Its

significance is enhanced by the fundamental relationship between water use and

quality/process control.
EXHIBIT 4: EA IN METAL FINISHING -- MATERIALS

TYPE OF COST SIGNIFICANCE ALLOCATION ASSIGNABILTY DATA GATHERING

 PRACTICE AND ACCURACY AND MANAGEMENT ISSUES

Plating materials Varies on type of plating Product level when high

volume material or

expensive (e.g. precious

metals)

Only assignable and

accurate where volumes

or material costs require

it

Data gathering, management and analysis limits

further ECA. Great care is advised in the decision

whether or not to allocate plating materials as part

of ECA.

Addition agents Enormous variation by

process. Brighteners

typically most

significant

Typically general

overhead , very seldom

at product or process

level

Large (and inexplicable)

variances found between

purchase and use

records suggesting

accuracy problems

Cost understanding appears to be poor in this area.

A scan for price and use volumes is definitely

recommended

Water Significant because of

relationship to both

environmental

management costs and

quality

General overhead, even

in high cost situations

Theoretically possible

but with

limited accuracy because

of valves in use (+ 20%)

Concurrent investments needed in monitoring and

control equipment; more pressing issue is selling

managers that this is worth doing

Solvents/

Other Cleaners

Alternative cleaners

increasingly significant

because of higher cost

and treatment challenges

Almost always in

general overhead

Possible to further

allocate but plagued by

general inability to say

with confidence how

much cleaner and

solvent use would

decrease

Must crosslink to quality and production

management data and operating procedures to

determine potential improvement numbers

Acids

Significant in some

applications (e.g.

electronics, plating on

plastics) ; not in others

General overhead

See cleaners; possibly

worse because of

perceived lower value of

information

Must crosslink to quality and production

management data and operating procedures to

determine potential improvement numbers

Filters Low, but

underrecognized

General overhead Process level is possible Because of its direct linkage to particular processes,

one of the better and simpler cost candidates for

ECA

Miscellaneous

Chemistries

Low but

underrecognized

General overhead Expected to have low

accuracy because of

information

gathering issues

Dispersed use patterns, episodic ordering and

general lack of other reasons to keep and track this

information
EXHIBIT 5: EA IN METAL FINISHING -- WASTE MANAGEMENT

TYPE OF COST SIGNIFICANCE ALLOCATION ASSIGNABILTY DATA GATHERING

 PRACTICE AND ACCURACY AND MANAGEMENT ISSUES

Wastewater

Treatment

Very significant Sometimes general

overhead, sometimes

allocated to department

by volume and/or

incidence

Possible, with some

effort, to calculate a

"$ /gal treated" value;

caution exercised given

elusive nature of

"incremental" savings in

treatment; best

examined when

eliminating a need

entirely

Value generation complicated by not knowing

 • what is really in waste water

 • when

 • how much it varies

Storage Varies, depending on

nature and size of

facility

General overhead, in an

established facility

waste management line

Unless eliminating need

entirely, reductions in

need seldom have

corresponding

reductions in cost

Recordkeeping demands implementation

Handling /

Disposal

Varies, depending on

nature and size of

facility

Typically overhead, in

an established facility

waste management line

but may be charged back

to departments

High and

straightforward on a unit

volume basis. High

accuracy excluding labor

Examination of percent regulated materials adds

information value

Insurance Overall significant but

very rare to find

insurance exclusively

pertaining to waste

management

Overhead in a general

and operations line.

Low, unless eliminating

need entirely, reductions

in need seldom have

corresponding

reductions in cost

Creation of cost per unit volume calculations

clumsy; facility unable to accommodate analysis
EXHIBIT 6: EA IN METAL FINISHING -- UTILITIES

 TYPE OF COST SIGNIFICANCE ALLOCATION ASSIGNABILTY DATA GATHERING

 PRACTICE AND ACCURACY AND MANAGEMENT ISSUES

Energy -

Electricity

Very significant Overhead - G&O line Very unlikely; would

require estimation of

cost per unit volume of

something that varies

constantly

Energy -

Steam / Natural

Gas

Significant Overhead - G&O line Very unlikely; no

examples found of

discrete component of

steam use for products

or processes

Sewerage Significant if special

surcharges have been

applied because of local

conditions and

requirements

Overhead - often a G&O

line

Possible to assign but

with very limited

accuracy because varies

continually. Can be

improved by insuring

segregation of process

related sewerage from

non-process related

sewerage

Concurrent investments needed in monitoring

equipment. Further complicated by the fact that

sewer charges often no direct relationship to the

amount of water actually being discharged from a

facility. Is, however, getting growing management

attention and may be ripe for ECA purposes.

Process Air Increasingly significant

with increases in amount

of source reduction

activity ( agitation,

blow-off, creation of fog

rinses, etc.)

Overhead G&O Possible by unit

operation but only

somewhat accurate

because of wide

variation in possible use

and amount of access by

operators

Cost of producing clean compressed air is difficult

to calculate
EXHIBIT 7: EA IN METAL FINISHING -- REGULATORY COMPLIANCE

TYPE OF COST SIGNIFICANCE ALLOCATION ASSIGNABILTY DATA GATHERING

 PRACTICE AND ACCURACY AND MANAGEMENT ISSUES

"Substance Driven

Costs"

(driven by use of

particular substances in

the facility)

Ã monitoring

Ã protective equipment

Ã lab fees

Ã manifesting

Ã labeling

Ã R&D to comply with

 regulations

Varies, depending on

nature of facility and

types of processes.

In total, can be

significant

Overhead G&O Assigned quite readily to

processes

Highly accurate when

linked to one source,

less accurate with

multiple sources in

facility

Recordkeeping demands limit allocation potential
"Regulatory

Response Driven

Costs"

(driven by generalized

need to respond to

regulations)

Ã reporting

Ã recordkeeping

Ã inspections

Ã notification

Ã handling

Ã fees, fines, penalties

Ã audits / plan

 preparation

Ã personal injury

Ã closure and post

 closure care

Ã insurance

Ã training

Ã consultants fees

Taken together, sum can

be significant

Overhead G&O Problematic without a

means to assign on a

volume basis.

Only somewhat accurate

Recordkeeping demands limit allocation potential
18

Direct Product Materials -- Assignment and allocation

Costs for coating materials are assigned at the product level -- especially among users of

precious metals -- and more of this type of assignment could probably be done.

However, it does not appear valid to use the experience of the users of precious metals as

a guide. Those companies are able to allocate costs at the product level because

extremely accurate records are kept of additions, precious metal concentration in the

process solution, surface area of parts, and thickness of precious metal coatings.

Base metals were only found to be allocated to the product level when it was either a high

volume material or when it was expensive for other reasons. In these circumstances,

allocation was found to be nearly always done using a gross multiplier during cost

estimation (e.g. 1000 square feet surface area to be plated to a thickness of .0005 inches

gets a "factor" of 20% added to the price.) This factor moves with the thickness and

sometimes the surface area. Greater allocation to the product level would be technically

possible, but probably be thwarted by the amount of record keeping required that is not

useful for any other purpose. Therefore, most allocations are likely restricted to the

process level. It is believed that this allocation would be accurate in nearly all cases.

Research suggests that costs for addition agents could probably be assigned but restricted

to the process level. It is believed that this allocation would be accurate in nearly all

cases. Costs for water could be allocated, but only with an investment in monitoring and

control equipment. Such investments have proven to be unlikely unless linked to other

facility needs. However, even if assigned, costs for water would only be somewhat

accurate, with an estimated variance of ± 20% as this is the estimated range for water

flow through the most common valves in use. Even in high cost situations, water was

found to be included with other general overhead charges and allocated in whatever way

the facility chose to allocate general overhead.

Indirect Materials Use -- Applicability and significance

In finishing operations, a wide variety of indirect materials are used in surface

preparation, in the finishing process itself, and in rework operations. As with direct

materials, there is a significant amount of variability concerning the absolute and relative

significance of indirect materials depending on the type of finishing operation. As

alternative cleaners replace traditional organic solvents, the significance increases in two
19

ways. First, they are more expensive to purchase -- research found situations where

purchase price of new cleaners exceeded old solvents by a factor of 12. Second, they can

be more expensive to treat, or at least this is the presumption.

Costs for acids are not particularly significant except in easily discerned cases such as

electronics; plating on plastics; and etching/deburring as pre-plate operations. Costs for

filters and miscellaneous chemistries tend to be small in most shops but underrecognized

and is therefore a good addition to EA.

Indirect Materials Use -- Assignment and Allocation

Costs for acids, filters, cleaning materials and miscellaneous chemistries (strippers,

chromates) tended not to be allocated outside general overhead. These materials

demonstrate dispersed use patterns, episodic ordering, and a lack of other reasons to keep

the required records (mostly use logs) thereby inhibiting process or product assignment.

Evidence from some facilities suggests that even if the allocation were attempted, it

would not likely be accurate because of a reliance on individual effort and a perception of

low value ascribed to the effort. Some evidence was found of allocation of cleaners to

product and in other situations by process, since it involves a discrete unit operation.

However, no approaches were found in the research that break that cost down between

solvent actually used to clean parts and solvent lost to evaporation. Therefore, costs are

likely to be completely accurate only where complete elimination is contemplated.

Where more efficient operations (increased freeboard; reduced withdrawal rate) are

proposed, costs are likely to be only mostly accurate.

By definition, process level allocation of filters is possible given that each filter is

"assigned" to a particular process. Product level allocation is impossible.

Materials Storage

A final category of cost analysis pertaining to materials is storage. These costs are not

very applicable to P2 analysis for electroplating operations. Most P2 options related to

materials storage involve replacing materials and equipment which still requires storage.

Research suggests that storage related to input materials is not usually a significant cost,

and not often connected with other costs likely to be analyzed.
20

4.2. Waste Management

Key waste management costs in electroplating

• Handling • Wastewater treatment -- labor, chemicals, energy

• Storage • Insurance

• Disposal • Transportation

Applicability and significance

Waste handling, storage, insurance, and wastewater treatment appear to have considerable

potential to elucidate a P2 project analysis. Typically, handling and storage costs are

subsumed together in a facility waste management line while insurance costs are often

found in a general operations line. Insurance pertaining specifically to waste

management operations is exceedingly rare. Insurance costs (overall) are clearly

significant in most operations.

Moving materials from place to place, especially as segregation increases, appears to

require considerable labor and equipment expense. Options short of elimination

(segregation to facilitate recycling, for example) appear to increase this cost burden.

Storage costs can be significant in larger operations where waste treatment areas can be

25% the size of production areas. In smaller operations these costs are marginally

significant and it is probably best to think of them in combination with other related

waste management activities.

Much of the cost analysis has its greatest relevancy when a facility is being designed.

Capital costs related to buying tanks, building storage sheds, diking warehouse areas, etc.

are very significant. Since sludge in many cases can only stay on-site for 90 days, the

relevance to pollution prevention project analysis is typically limited to those

circumstances when a massive overhaul could possibly prevent the need to build more

storage. The same logic applies to insurance costs since systems/options can be

assembled that could, if done well, change risk categories. Research suggests that a

pollution prevention option that reduced the need for storage would not reduce the costs

of storage, or at least not very often. Likewise an option that reduces the need for storage

seldom reduces the costs of insurance.
21

The primary and priority cost center, operation and maintenance of a conventional

wastewater treatment system, combines a wide variety of labor, chemical, and utility

costs. The significance of cost burden for facilities is high and made higher by the need

to reduce chrome or oxidize cyanide if those processes exist in a facility. Costs may also

be unnecessarily inflated by less than optimal management practices. Similarly, the use

of recovery technologies as "pretreatment" to the treatment system carries potentially

significant costs and will generate wastes themselves. Caution must be exercised when

reviewing cost implications of this technology use since costs appear to be shifted as

often as they are actually reduced.

Assignment and allocation

Allocation of waste storage and handling costs only to processes or products generating

the need for handling appears straightforward, especially when considered as part of the

overall waste management line. Typical assignment would be on a unit volume basis.

Insurance, however, poses a more challenging problem, and allocation of these costs only

to processes or products generating the need for some discrete component of insurance

seems unlikely. Such an insurance line item would involve estimation and/or calculation

of the cost per unit volume to insure activities that seem hardly to be recognized in

policies as risk vectors.

The accuracy of waste management costs is difficult to ascertain. It is doubtful that these

costs could be readily audited, since it relies heavily on a labor component that would in

turn rely on individuals differentiating their activities. Accuracy even of the overall

waste management line is also somewhat suspect, since records seem to rely upon time

assigned to duties, rather than tracking of actual time spent.

Wastewater treatment system costs typically appear as an overhead charge and are most

frequently allocated across all processes based on square footage of production or some

other related measure. Occasionally facilities were found in which veteran estimators

knew that certain processes created larger treatment burden than others and made some

attempt to differentiate charges. This practice, however, more often occurred in response

to pricing sensitivity rather than to seek an understanding of the "true costs." In other

words, more refined allocation measures were employed to figure out a way to pass the

cost on rather than reduce it. In other, typically larger, facilities the treatment system was
22

a cost center with charge-backs to departments based on volumes and/or incidences such

as bath dumps. However, charge-backs appear to be based on rather crude calculations.

4.3 Utilities

Key utility costs in electroplating

• Energy

• Sewerage

• Process air

Energy -- Applicability and significance

Electricity in general as a cost to electroplating facilities is extremely significant.

However, its applicability as an area of cost analysis for pollution prevention purposes is

inherently limited. By far the majority of electricity goes for application of coatings in

heating and electrodeposition which have physical limits to their efficiency and is

therefore rarely the focus of pollution prevention analyses. Steam and natural gas is used

in some facilities for process heating, and for facilities with large boilers or ovens, this

can be a significant cost. It also may, in some cases, be part of the need for an air permit.

Natural gas may also be used for firing bake or dry ovens. These costs are nearly always

subsumed in a "general operations" line.

Energy -- Assignment and allocation

Allocation of these costs only to processes or products generating the need for some

discrete component of power or fuel use seems unlikely. This cost seems nearly

impossible to allocate; it would involve estimation and/or calculation of the cost per unit

volume of something that varies constantly; at a minimum, significant investment in

monitoring equipment would be required. Likewise, assignment of steam costs only to

processes or products generating the need for some discrete component of steam use

seems unlikely.

An interesting sidelight discovered in the course of the research is the use of electrical

consumption as part of a ratio to adjust measures of P2 progress. The theory is that use of
23

electricity declines when work activity declines, so a electricity/water use ratio could be

derived that would shed some light on whether water use declined as a result of P2

activity or a decline in business activity. Unfortunately, this would still be very hard to

use at anything other than the facility aggregate level.

Sewerage -- Applicability and Significance

Sewerage costs should be applicable to the analysis of any facility and any specific

pollution prevention project dealing with water use and water waste streams. It is

worthwhile to note that sewer charges can and are computed in many different ways --

many of which have no direct relationship to the amount of water actually being

discharged from the facility. Some facilities have a standard sewer charge based on

inputs into the facility rather than outputs. Others feature a cost computation based on

broad categories rather than actual amounts -- for example the size of pipe combined with

the amount of water purchased is determined to be equal to the amount of water sewered

with a multiplier applied to monthly activity. Sewer costs can be especially significant if

special surcharges have been applied because of local conditions and requirements.

These costs are nearly always subsumed as part of other categories.

Sewerage -- Assignment and Allocation

It appears possible to assign these costs to processes or products generating the need for

some discrete portion of sewer use. However, as with other utilities, this cost seems

nearly impossible to allocate accurately as it would involve estimation and/or calculation

of the cost per unit volume of something that varies continually. As with other utilities

an increase in accuracy would require significant investments in monitoring equipment.

The quality of cost analysis and assignment in sewerage could be improved, however, by

separating process-related from non-process-related sewerage. The research found many

instances of large volumes of non-contact cooling water, water from cooling towers,

domestic sewerage and even storm water being combined with process water, thus raising

volumes and charges or, at a minimum, obscuring industrial use information which would

be the focus of a P2 project analysis.
24

Process air -- Applicability and Significance

Costs for clean process air, especially compressed air, may be applicable to a P2 project

analysis -- although the issue here is ensuring that this cost is accounted for in the

economic analysis of the P2 option. Clean compressed air is an important component in

several "keystone" source reduction concepts for electroplating facilities, e.g., dry air

blow-off of process solution to reduce water use; clean air to increase agitation in water

rinses and reduce need for water use; warm air mixed with water rinses to create "fog"

rinses and reduce need for water rinse. A facility implementing the above source

reduction option could easily outstrip existing compressed air capacity, especially since

clean and/or dry is quite expensive to generate. These costs are often not significant, but

may become significant with substantial source reduction activity. Several facilities

contacted in the research reported costs for air outstripping costs for some acids. These

costs are always subsumed in a general operating category

Process air -- Assignment and Allocation

Assignment of these costs by unit operation are possible, since most applications are

designed with specific flows both required and controlled. However, two complicating

factors exist. First, the cost of producing clean compressed air is difficult to calculate as

no generally accepted default values were found to exist during the project research.

Second, this allocation would only be somewhat accurate because of the wide variation in

use possible and the amount of access by operators to the system

4.4 Direct Labor -- Clerical and Inspection

Applicability and Significance

Because pollution prevention projects in electroplating typically have strong process

control, recordkeeping, monitoring, and analysis themes associated with them,

manufacturing clerical labor expenses will tend to be applicable. P2 project analysis

may also require specification and contract review, another purpose for which

manufacturing clerical labor would be used. These can be significant costs in many

operations

and are related to similar activities undertaken to improve quality and/or productivity that

may be part of a P2 project analysis.
25

Some P2 projects may also affect the need for parts inspection, especially in cases where

overall process quality is improved or a particular finish is modified. Therefore, these

costs may be applicable to P2 project analysis, albeit marginally. Research found that

inspection costs are part of overhead in about 50% of facilities investigated, and part of a

separate quality management and documentation system in the other 50% of facilities. In

the latter case, inspection costs are sometimes identifiable as separate costs, but not at the

product or process level. In a few cases of high-volume or sophisticated products,

inspection costs may be both specific and allocated. Inspection activities tend not to be

significant costs. In addition, the "quality revolution" has caused most inspection

activities to be combined with the production duties of operators, which further reduces

the significance of the costs, since inspection is almost always done in the "down time"

that occurs while waiting for parts to be processed.

Assignment and Allocation

Manufacturing clerical costs could be assigned, but only in settings where workers in

these labor categories already use activity coding for other purposes, or are specialists

who could respond accurately to interview-based analysis. Allocation of these costs

seems to be only somewhat accurate, apparently because a "life cycle" of recordkeeping

was found in project research -- intensive in the early stages of project analysis, decreases

to a somewhat lower level during decision making and implementation, and may

disappear entirely at a later point. However, several cases were described that

incorporated the new records and analysis into quality monitoring systems, thus

permanently increasing these costs.

Assignment of inspection costs seems to be unlikely and, if attempted, inaccurate.

4.5 Indirect Labor

Applicability and Significance

Applicable indirect labor elements in electroplating includes maintenance and medical

surveillance. Maintenance costs do appear quite applicable to a P2 project analysis and

can come in many forms. Process solution maintenance tends to be done by production

operators, with significant exceptions in the electronics products and aerospace industry
26

sectors. Mechanical maintenance is usually done by specialists, either in-house or

contracted. Maintenance done by operators is often done during down time while

waiting for parts to process, and may or may not be recorded separately while

maintenance done by contractors, in-house specialists, and for special projects (process

solution changeover on a weekend, for example) are often recorded and tracked through a

system of work orders or job sheets. These costs are often significant, especially in larger

facilities.

Medical surveillance costs may be applicable to a P2 project analysis, especially if the

project contemplates eliminating particular substances or unit operations which cause the

need for monitoring. These activities are nearly exclusively performed by clinics or

outside contractors and are accessible as separate line items only in rare cases. In most

facilities, these are treated either as "general operating" costs or even as part of "employee

benefits." These costs are apparently only significant in a small group of facilities, but

the cost significance issue may be rendered moot. Even if the P2 option reduces or

eliminates the need, monitoring may still be either required, prudent, or very desirable.

Assignment and Allocation

Maintenance done by contractors, in-house specialists, and for special projects could

probably be allocated accurately to the process or unit operation level. However,

maintenance done by operators is probably impossible to assign separately unless

supported by a work order / paper trail and distinguished from production activities.

Assignment of medical surveillance costs seems likely to be possible and will probably

be quite accurate, inasmuch as they are driven by specific monitoring and not general

screening.

4.6 Regulatory Compliance

Applicability and Significance

As with other industries, electroplating features an extensive array of cost items

pertaining to the regulatory compliance and the environmental management function. For

purposes of analysis, it is useful to segregate these compliance costs into two categories --
27

those driven by a facility's use of particular substances and those driven by the facility's

generalized need to respond to environmental regulations.
28

 Substance-driven costs would include:

• monitoring

• protective equipment

• lab fees

• manifesting

• labeling

• R&D to comply with regulations

These costs are usually applicable to a P2 project analysis and typically subsumed in a

"general operating" category. Of this list, lab fees and monitoring can often be significant

costs.

Regulatory response driven costs would include:

• reporting • closure and post closure care • handling

• recordkeeping • personal injury • fines and penalties

• inspections • notification

• insurance • training and materials

These costs are usually applicable to a P2 project analysis and usually subsumed in a

"general operating" category. With the exception of closure which can be associated

with very high costs, the individual cost elements may not be very great. However, taken

together, their sum can be quite significant.

Assignment and Allocation

The purpose of distinguishing these compliance cost categories lies in their ability to be

assigned to processes or products. The former set -- use driven costs -- can probably be

assigned quite readily and the allocations would probably be quite accurate. Costs

associated with generalized compliance response prove far more problematic. They can

probably be assigned only on a volume basis (e.g. 10% of sludge is nickel so 10% of cost

pool goes to nickel processes). Such assignments would only be somewhat accurate.
29

4.7 Incremental Revenues

Applicability and Significance

Revenue accruing from the production and sale from a marketable byproduct is common

in electroplating and applicable to P2 project analysis. Most electroplating facilities

selling byproducts seem to include these revenues as part of a general income line. These

revenues tend not to be very large components of gross revenues and, furthermore, vary

considerably because of their exposure to price swings in commodity markets. As a

result,

reliance on these revenues for cost/benefit analysis when doing project analysis is fairly

rare.

Sales increases as a result of image improvements might be possible, but the research

found no instance of a facility willing to consider this approach to valuing the results of

P2 projects.

Assignment and Allocation

Byproduct revenues can be allocated accurately, but generally cannot be projected for use

in capital budgeting efforts.
30

5.0 ISSUES IN IMPLEMENTING ENVIRONMENTAL ACCOUNTING 

IN ELECTROPLATING OPERATIONS

Electroplating firms contacted and visited for this project have recognized that waste

management and regulatory compliance involve more costs than those in evidence as

totals on just the checks written to treatment and disposal firms. In addition, these firms

are seeing that more benefits accrue to their facility -- and financial statements -- from

pollution prevention approaches than has usually been portrayed in the past.

EA has a role in facilitating this understanding, supporting better project analysis, and

prompting more implementation. A generally accepted EA implementation strategy is

comprised of the following steps:

• Identify environmental management costs

• Prioritize and select the costs to investigate in more detail

• Quantify or qualify the costs

• Allocate costs to products or processes responsible for their generation

• Integrate costs into facility decision-making

Following is a discussion of the relevant issues pertaining to each of these steps as they

relate to finishing operations.

5.1 Identifying Environmental Costs

As the following table illustrates, environmental management costs in electroplating

facilities might best be broken into two primary categories -- 1) direct and indirect

operating costs associated with environmental management and compliance and 2)

opportunity costs stemming from not using raw materials as efficiently or as productively

as possible. The direct and indirect costs associated with environmental management

issues highlighted in the previous tables vary in their relevance to finishing operations

and in their "ability" to be identified depending on the types and nature of processes

employed at the facility. Generally speaking, however, these direct and indirect costs can

be quite readily identified by a facility. Those which require actual checks on a regular or

semi-regular basis were quickly identified by the facilities visited and leave a paper trail
31

in the system. Smaller, more miscellaneous expenditures such as regulatory fees were

also identified with some limited prompting.

 Environmental Cost Components3

Type

Environmental Management

Costs

Lost Material Costs

Examples

Ã labor cost for environmental

 compliance

Ã regulatory fees

Ã purchased materials for water

 treatment

Ã wasted process solution

Ã lost process chemistry

How Identified

Cost Accounting Review

 Ã general ledger review

 Ã payables review

Cost Accounting Review plus

Process Review

 Ã materials balance

 Ã process benchmarking

Environmental management costs which do not involve monthly check writing (e.g.

indirect labor, etc.) were also readily acknowledged by facilities and recognized as

something which should be reduced. An important complicating issue here, however, is

the degree to which facilities can link them to specific activity drivers (e.g. separating the

indirect labor pot into its components of recordkeeping, monitoring, notification, etc.).

Although facilities recognize their existence, they proved to be far less willing or able to

identify costs at this level of individual detail. From a standpoint of EA analysis, such an

effort may not be necessary given the relative size of these items in relation to other cost

elements.

The drivers of these direct and indirect costs, rather than the costs themselves, were most

often underrecognized by a facility. This was especially true in target areas such as

wastewater treatment and hazardous waste disposal. While facilities could generally

develop cost totals for these areas, the understanding of the contribution and impact

episodic events such as disposal of tank bottoms, rework of reject parts, and bath dumps

have on these items was underrecognized. Applying environmental accounting to these

 3 Two other cost categories which may be a part of environmental management costs are contingency costs

and image costs. However, a consideration of these costs is not included in the report. See Section 3.0
32

activities was found to generate interest in reducing the frequency of these events through

better process management and control.

A larger and more significant set of environmental costs for electroplating are the

opportunity costs of unoptimized materials use. These opportunity costs are the value of

lost process materials -- materials purchased but not sold, wasted, or not used as

efficiently or as productively as could be. They are implicitly more difficult to identify

for the following reasons:

• There are few readily available "best industrial practice" benchmarks to indicate

to a facility how efficient or productive their processes could be from the

standpoint of materials use.

• Reviews of electroplating cost and pricing literature found no way to track lost

material through explicit or implicit loss allowances. It may exist in some

electroplating facilities for very specific reasons, but nothing was uncovered in

this project research.

• Cost accounting systems do not capture such opportunity costs with a line item

called "wasted raw material." In fact, the opposite may be true -- cost accounting

systems may artificially hide this cost of waste by building costing systems on

standard loss allowances rather than actual losses.

Adding the opportunity costs with the direct and indirect environmental management

costs gives a facility a more accurate measure of the facility's total cost of waste. They

are also obviously interrelated: reduction in these opportunity costs will decrease primary

environmental management costs such as wastewater treatment and hazardous waste

disposal.

5.2 Prioritizing Costs to Investigate

For reasons described above, facility attention should first be focused on valuing the

opportunity costs of materials losses before attempting to "unpack" environmental

overhead in deeper levels of EA analysis. The research showed that for electroplating

facilities the significance of environmental management overhead items generally pale in
33

comparison in amount and significance to these opportunity cost issues. For example, in

one of the zinc shops visited:

 Apparent cost of F006 sludge based on payments to TSD and hauler: $525/ton

 EA-generated share of overhead cost $67/ton

 Apparent cost of sludge adjusted for allocated overhead $587/ton

 Cost of lost process chemistry 4 $306/ton

 Cost of sludge adjusted for environmental management and

opportunity costs $893/ton

In this example, the opportunity costs of lost material exceeded the overhead allocated

costs by a factor of nearly five. In many of the shops visited, opportunity costs exceeded

environmental management costs by a factor of ten.

The opportunity costs likely to generate motivating numbers for the facility to consider

are:

• value of lost process solution and chemistries

• excess water use

Once this understanding is gained, it can be used as part of the analysis for other direct

"big ticket" EA cost items such as wastewater treatment, sewerage, and waste disposal.

For example, every gallon of excess water use creates an environmental management cost

that is typically undervalued. Care should be taken to always divide total environmental

management costs related to wastewater into wastewater volume since EA analysis has

shown that wastewater costs can be surprisingly high.

5.3 Quantifying or Qualifying Costs

Efforts to quantify environmental management costs begin with the ability to access cost

information. Assuring the accuracy of this quantification effort is equally important.

 4 [Sludge at 1% zinc metal/ton = 320 oz. zinc metal/ton) ÷ (zinc cyanide plating solution at 4.7 oz/gal)] x

(zinc cyanide plating solution at $4.50/gal) = $306.38

 ̊
34

Quantifying direct and indirect environmental management costs, as described earlier,

can be quite straightforward for certain items (those with invoices) and less so for other

elements (e.g. labor component, liability). The challenge found throughout project

research was the ability to quantify these costs at a level of detail to help facilitate an EA

analysis. Electroplating facilities visited and contacted for this project tended to

aggregate many costs into very general categories, at least when preparing financial

statements such as balance sheets and profit and loss statements. Moreover "mining"

this information at a level of detail necessary to enable allocation is potentially an

expensive thing for a facility to do and there often appears to be no other particular

production or management reason for collecting and managing information at this level of

detail. Without other opportunities for using this information, its collection and

management is even less likely for a facility.

Labor costs are often major components of "hidden" environmental management costs.

Both direct and indirect labor are captured on the general ledger and subsequent

statements as aggregated costs. Supporting documentation, usually time sheets, use

codes, part numbers, job names, or similar appellations are used to distinguish between

work activities for production and support staff, and usually use considerable less detail

for salaried personnel, e.g., a manager in charge of research and record keeping for

regulatory compliance. These can be used to help allocate costs to responsible products

or processes. However, two issues arose which affected the use of labor costs in an EA

analysis:

• Minimal or no effect on cash flow -- In no facilities reviewed would a strategy

offer the potential to actually reduce labor costs in such a way that cash flow is

affected. Discussions with facility representatives on the labor valuation issue

suggested a hesitancy to assign "savings" to activities which did not directly affect

payroll or payables.

• Need to recognize labor trade-offs -- Facilities recognized that reducing

necessary investments in environmental labor offered the potential to reallocate

human resources to more productive activities. However, finishing facilities are

quick to point out that whatever pollution prevention technique or technology is

being evaluated is likely to also have its own increases in labor costs.

Environmentally preferable processes or recovery technologies typically have

tighter operating windows requiring more careful monitoring practices and new
35

standard operating procedures. Recovery technologies typically are quite

sophisticated demanding increased maintenance, monitoring, training and control

efforts. The National Association of Metal Finishers has reported technology

failure rates of 30-40% for various types of recovery technologies within the

industry, and experts believe a portion of this failure may be due to labor issues

and the sophistication of the technologies.

It is clear that environmental labor issues are important and relevant to an analysis, and

decreases in regulatory-related labor activities of all types is certainly in the best interest

of a facility. Many facilities also seem to benefit from quantifying these labor costs to

obtain an understanding of the potential productivity gains which may be available.

However for actual economic evaluations of projects, many of these labor issues might be

best factored into an analysis in a qualitative fashion.

Quantifying the opportunity cost component is an ongoing challenge of finishing

operations because it requires an ability to assess "how good the process could be."

Quantifying the opportunity cost component faces two key problems:

1) Accuracy of cost information is frequently questionable -- The reality in

electroplating is that only information based on an invoice or similar

documentation can be trusted to be completely accurate. Data derived from

internal records and calculations, or even from interviews of personnel, are at their

most reliable still highly variable, simply because of the ever-changing nature of

electroplating operations. Some facilities will add to that variability with spotty

record keeping, personal bias, and lack of equipment for proper monitoring. The

only exceptions seem to be records that are also required to be kept for other

purposes, such as demonstration of compliance with customer specifications or

documentation for quality management systems.

2) Need for strong supporting production information systems -- Robust

production management information is needed to be able to support the EA

analysis and numbers. In parallel with the system of bookkeeping and accounting

is the record keeping and analysis required to produce job cost estimates, schedule

production and maintenance, do short- and long-range company planning, and

track and assure quality. This system tends to be less accurate, mostly because it

is heavily influenced by subjective responses, records kept by humans, and the
36

ebb and flow of customer demands. This is the very system that must produce

documentation that would be used to cross-check estimates (acid purchased vs.

acid used), analyze options (length of time required to rinse "thoroughly"), and

gauge information needs for implementation (estimated down time for conversion

to non-cyanide zinc).

5.4 Allocating Costs to Products or Processes Responsible for their 

Generation

The question of whether to allocate to processes or products depends on the type of

project being investigated. Some pollution prevention technologies -- ion exchange,

reverse osmosis, replacement of organic solvent cleaning, cyanide elimination, and

others--are best supported by cost allocations to the process level. That is to say, as many

costs as possible that are associated with a given process (the "target" of a pollution

prevention technology) should be dis-aggregated and made part of the pollution

prevention project analysis. Cost of process solution, cost of utilities, cost of labor: all

become a legitimate part of the analysis. In that case, the technologies and allocation

level "match"--what is needed happens to be for the most part available.

For other projects -- especially those having implications regarding water use, procedure

modifications, or process re-design -- allocations to the process level are often

insufficient. The success of these projects is many times product-specific, meaning that

the relative effect of a product on the costs of operating a process is at least as important

as the costs of process chemistry and waste management costs associated with a process.

In these cases, pollution prevention project analysis requires knowing not just how much

a given process costs in terms of process operations and waste treatment, but also what

percentage of those costs are caused by Part A , Part B and Part C. Cost allocation at the

product level is quite rare.

For most facilities visited, how to allocate was typically a greater issue than on what level

to allocate. As in quantifying costs, individual pieces of EA analysis vary in degrees of

difficulty with respect to allocating to their sources. Three allocation options facilities

may consider are allocations based on actual contribution, allocations based on estimated

calculations, and allocations based on professional judgment.
37

5.4.1 Allocation Based on Actual Contribution

Most of the "hidden" environmental management costs -- are extremely difficult to

allocate based on their actual contributions. The number of product and process variables

affecting actual contribution are typically too complex and systemic for most finishing

facilities to be able to (or want to) generate actual contribution numbers. This is true

even for the high profile environmental management costs. For example, in many shops,

a large environmental management cost is the system used to satisfy the limits on

concentrations of various materials in wastewater discharge permits. In order to

accurately allocate to the process level the costs of creating and managing metal

hydroxide sludge, a shop would have to account for:

• variation in product mix

• potential variation in operating procedures

• variation in chemical concentrations

• potentially numerous sources for each constituent of concern

A review of the literature found company examples that had documented in excruciating

detail the relative contributions of different parts and solutions to different wastewater

streams. Site-specific data were in fact generated, but so many variables were controlled

as to render general transferability of this data to other facilities completely moot. The

research required to allocate large costs like water, sludge generation, and concentrated

process solution disposal appears to be too complicated and too expensive to be

conducted by any but the most sophisticated electroplating operations.

5.4.2 Allocations Based on Estimated Calculations

Given these inherent difficulties, facilities have responded by allocating these costs based

not on actual but estimated contribution. Estimations are typically generated in one of

two ways -- using standard surcharges or "kickers" which the facility uses to price

products; or using activity based measures.

Standard surcharges are commonly found in electroplating. A finishing operation might

add 15% to the cost of the chrome finished products to cover treatment costs, but a 30%

charge to cover cyanide processes. These percentages might also be used for cost

allocation purposes. This approach is well-accepted in the industry. WRITAR found
38

evidence in our research of using "default values" based on sources such as the plating

literature, discussion with peers, and personal or organizational experience. However, as

with labor costs, these surcharges are "loaded" with extraneous costs not pertinent to a

pollution prevention project analysis; typically assembled to recover production costs, not

to reveal activity costs; and therefore yield high levels of inaccuracy.

An alternative way to allocate is through engineering estimates. Environmental

management activity is first subdivided into separate categories of activity (e.g. cyanide

destruction, chrome reduction, etc.) These activities are then assigned a cost, in this case

usually on a "per gallons treated" basis by calculating the predicted costs of treatment for

a specific concentration, flow, method, etc. These controlled variables are chosen to be

nearly representative of actual facility conditions as possible, and the cost is "built" by

analyzing each step of the process. Engineering estimates have higher levels of

accuracy, and the greater the controlled variables reflect facility reality, the more accurate

the estimates will be. Developing engineering estimates, however, is a sophisticated,

technically demanding effort, and may be outside the scope of non-process experts.

Allocations based on an appropriate production factor (square feet processed, hours of

operation, etc.) is perhaps the simplest type of estimated calculation and a possible

short-cut to full engineering estimates. This allocation approach can be complemented

by electroplating literature which will contain published industry averages like "dollars

per gallon treated." Users however must recognize these estimates are averages and can

vary significantly based on the production factors cited earlier (product configuration,

concentration, flow, other materials in waste stream, etc.) As an example, in the

hexavalent chrome facilities visited for this project, the dollars per gallon chrome

reduction estimates varied by a factor of 22. As a result, production factor allocations

are probably best used when high levels of accuracy are not determined to be critical.

5.4.3 Allocations Based on Professional Judgment

Another response to the difficulty of deriving actual values from records in electroplating

is deriving relative contributions of the different components of an aggregated

environmental cost using the best judgment of facility staff. Because real numbers are

not generated, this approach is not used for capital budgeting. However, it could be used

for targeting opportunities and prioritizing improvement activities.
39

To evaluate the efficacy of this approach, WRITAR had facility staff generate

contribution estimates based on professional judgment. The costs were then allocated

accordingly. These cost allocations were then cross-checked through WRITAR's

assessment

procedure5 .

The best "match" between "estimated" allocation and assessment-based allocation was

obtained when the following constraints were met:

• Production records already gathered and analyzed for other purposes

• Process analysis and control was documented and cross-checked by supervisor

• Approval was required for discharge to treatment

• Waste treatment and environmental management staff familiar with 

production operations

However, in only three facilities did staff allocation estimates come within 25% of what

were eventually accepted as somewhat accurate allocations (see earlier definition in this

report). In several facilities variances were as high as 400-500%.

Many interpretations are possible of the basis for these inaccuracies. The most likely,

based on our research, is that many electroplating operations rely on cost structures that

are very general unless allocation is required by some outside force (customer,

shareholder, banker, etc.). This leads to working with and accepting information that is

perfectly acceptable for day-to-day operations, but which can falter when brought to bear

on a more rigorous and detailed effort such as improvement targeting. As a result,

allocation based on professional judgment should be interpreted with caution.

5.5 Integrating Costs into Decision Making

EA has potential application in several areas of facility decision-making including capital

budgeting and targeting of improvement actions. The following section describes some

 5 WRITAR's assessment procedure entailed an allocation based on engineering estimates and materials

balances. Materials use amounts were generated from a variety of production records and cross checked.

Electroplating engineering handbooks were then used to calculate the amount of process consumption

which would be necessary to accomplish the facility's production volumes and specs. The balance would

be considered lost process material requiring treatment.
40

of the research findings and conclusions about EA use in these two decision situations for

electroplating shops.

5.5.1 Capital Budgeting Decisions

In the sample of shops visited, conventional costs were routinely captured in project

analysis. In six of the shops in our sample, parts of EA addressing direct and indirect

costs associated with environmental management had been used to justify pollution

prevention projects requiring capital investments. The parts of EA selected focused on

large environmental costs that could be fairly easily allocated because they were either

comprised of the costs to manage a single waste or type of waste that would be eliminated

(e.g., switching from organic solvents for degreasing to aqueous alkaline cleaners) or

because the linkage to environmental management costs was completely obvious (e.g.,

eliminating cyanide inputs from the flow-through portion of the pretreatment system

which reduced disposal costs and eliminated the need for a unit operation). Many shops

have been using parts of EA without knowing it or calling it that, much like the way

shops do "pollution prevention" without calling it that in the normal course of improving

operations.

The idea of consistently applying a full EA framework including contingent and image

costs did not seem likely to any representatives in the sample. There is a very strong

sense of individuals using only what is 1) high-potential in terms of cost reduction, and 2)

solid in terms of accuracy. Although facilities found indirect costs (those not directly

affecting payroll and payables) useful to consider and quantify, metal finishers

demonstrated hesitancy to formally factor them into an actual economic evaluation of a

project. Electroplating facilities were strongly oriented toward using conservative cost

estimates in decision-making.

A broader issue concerns the type of capital projects best supported by EA analysis. The

optimal situation occurs in capital projects in which entire operations such as cyanide

destruction, chrome reduction, or solvent cleaning can be eliminated. This avoids the

need to engage in difficult allocation mathematics. However, research found that in most

cost areas, process substitution results in incremental reductions rather than complete

elimination. For most of the facilities, some cyanide destruction and chrome reduction

capacity needed to remain because of other processes in the facility. While theoretically

an estimated savings based on volume reduction might be generated, the problems of data
41

quality and tracking and allocation challenges arose. No shop in the zinc cyanide sample

could approach being able to figure out a percent contribution by source for cyanide

destruction. Difficulties of this nature are found in other EA cost categories including

waste management and regulatory compliance costs. As a general rule, the best

candidates for a more fully developed EA analysis are those that are focused on a single

waste stream and address complete, rather than partial, elimination of environmental cost

categories.

Perhaps the most useful application of EA in the capital budgeting area is to help the

facility make better choices on the types and sizes of capital projects needed in the

facility. The need to invest in process optimization before making capital budgeting

decisions has long been recognized in electroplating. Perhaps the best example of this

principle can be found in efforts to create a closed looped wastewater system. According

to Plating and Surface Finishing (October, 1993) a pursuit of zero water discharge

without upfront process optimization can cost a facility 2-5 times more than conventional

end of pipe treatment. Using EA to examine costs of loss material in a facility and

identify where process improvement is prudent can provide valuable input into facility

capital planning.

5.5.2 Targeting and Prioritizing Improvement Opportunities

EA also has value in targeting and prioritizing improvement opportunities for facility

operations. However, the key to targeting was again found to be rooted in understanding

and quantifying the cost of the lost material portion of an EA analysis. Moreover, to

obtain the best results, EA is best used in conjunction with traditional targeting methods

such as reject rate analysis to get the best environmental as well as financial benefit.

Targeting improvement areas based solely on relative contributions to facility

environmental management overhead and ignoring lost material issues may misdirect

facility attention from where the greatest gains could be realized. WRITAR compared

the results of targeting based solely on contributions to environmental overhead with

those based on an assessment approach based on materials accounting and lost process

solution. The best "match" between allocated overhead based targeting and assessmentbased targeting was obtained when the following constraints were met:

• Limited variation of products
42

• Limited use of multiple-use process solutions (other than rinses)

• Limited total number of processes

The project lacked sufficient resources to define "limited" in much detail, but this much is

clear: When the total of the number of products plus the number of multiple-use

solutions plus the total number of processes (yielding total "factors" ) exceeded 20, the

overhead focused methodology actually became worse than a guess, since it actively

misdirected the investigation because of its issue-specific approach. As an example, a

manufacturer of nickel-plated hand tools:

--has three products

--uses two different cleaners, two different acids -------------> Total "factors" = 9

--uses two electroplating solutions

In this extremely simple, probably anomalous, production situation. the overhead

allocation method and the assessment method both pointed to the nickel plating solution

as being the most deserving of P2 attention with the goal of reducing environmental

management costs. (In this case, the calculated approach focused on allocating water,

sewer and sludge costs because of the effect of wastewater volume on total sludge

volume.)

In a more typical (at least for this coating/product mix) production situation, a

manufacturer of enclosures for the electronics industry which are zinc plated and

chromated:

--has (on the one line chosen for analysis) 12 "primary" products

--uses two cleaners, three acids ----> Total "factors" = 21

--uses one electroplating solution, three chromate solutions

In this case, the target recommended by environmental overhead allocation (once again

allocating water, sewer, and sludge costs) was the chromate portion of the process.

However, the assessment-based approach pointed to the zinc solution and related process

control issues (because of the effect on reject rates and corresponding impacts on

materials use and waste issues), with the chromates a close second. As the cases

examined increased in "complexity", at least as indicated by the "factors" approach used
43

above, the two approaches pointed less and less frequently in anything like the same

direction.

Targeting based solely on the allocation of environmental overhead may not result in the

best projects in terms of environmental and financial returns. Targeting based on an EA

analysis which first examines loss process solution costs and then allocates environmental

management cost components can be a powerful targeting tool.

5.5.3 Applying EA to Hexavalent Chrome and Zinc Cyanide Substitution 

Projects

To examine and illustrate some of the issues and challenges of EA analysis in pollution

prevention projects, WRITAR investigated two plating processes that appeared to be best

tailored to potential EA application -- substitution of zinc cyanide processes and

substitution of hexavalent chrome processes. Besides being regulatory targets and

therefore the focus for existing change efforts, these two processes appeared to satisfy the

condition of well defined, technology-based changes which appear to be very amenable to

EA analysis.

WRITAR visited eight shops using zinc cyanide processes and ten shops using

hexavalent chrome processes for decorative plating. Working jointly with the facilities,

WRITAR applied an EA analysis to the decision on whether to switch to appropriate

alternatives.

With the exception of two cost categories -- utilities and insurance -- WRITAR found that

applying EA methodologies offered the potential for elucidating and incorporating other

costs which would help justify a process change. However, three issues arose which are

likely to be found in other types of project evaluations:

1. More cost savings is not necessarily the implementation key-- Because of the

regulatory pressures, nearly all the firms were already quite aware of the general

economics of alternative processes. That the economic justification could be "beefed up"

was generally not an issue. General resistance to change, inability to change due to

perceived or codified requirements, labor skill base, and other factors rather than the

numbers were stopping implementation. This issue is not a fault or limitation of EA;
44

rather, it simply demonstrates that cost is just one of a multitude of potential issues

affecting pollution prevention implementation.

2. EA analysis is better served by decision situations featuring complete, rather

than incremental reductions -- As discussed earlier, allocation challenges created the

major roadblock for EA analysis. In facilities where entire operations such as cyanide

destruction or chrome reduction could be eliminated, EA offered tremendous potential.

The corresponding environmnetal management and regualtory costs associated cyanide

detsruction could be readily assembled and factored into the analysis. However, research

found that in most cost areas, process substitution result in incremental reductions rather

than complete elimination. For most of the facilities, some cyanide destruction and

chrome reduction capacity needed to remain because of other processes in the facility.

While theoretically an estimated savings based on volume reduction might be generated,

the problems of data quality and tracking described earlier immediately came to the

surface. Difficulties of this nature were found in other EA cost categories including

waste management and regulatory compliance costs.

3. Indirect labor costs exist for alternatives as well -- Indirect labor "savings"

associated with environmental management could be roughly approximated, but full

costing demanded "equal time" on the other side of the ledger and labor cost changes

were approximated for alternative processes. Many of the environmental management

labor savings were offset by increased labor costs associated with the alternative

processes which generally demand more careful maintenance and control practices and

embodied their own training issues.
45

6.0 GUIDANCE FOR INVESTIGATING LOST MATERIAL COSTS IN 

ELECTROPLATING

Because the environmental management cost structures of a facility are really a function

of how and how well materials are used in operations, obtaining an understanding of

existing process performance and materials use is a good starting point for EA in

electroplating. Investigators should begin by exploring what types of efforts have been

made to:

improve process controls

reduce water use

understand and optimize materials use

implement and monitor standard procedures

to obtain a sense of where facilities have and have not invested in process improvement.

Once this understanding is gained, the economic justification for further activity can be

made through an application of EA. The value of waste as lost process solution is the

critical calculation worth performing since it provides a sense of the opportunity costs

available to the facility, identifies the best cost-saving targets, and it can be very useful as

part of the disposal costs portion of an EA framework. This can be done through the

recommended steps described below. These opportunity costs can then be added to the

EA-generated environmental cost numbers (which capturing the environmental

management cost components) to get the true "cost of wasting."

Linking environmental management costs to ongoing improvement needs proved to be

another useful way to generate facility interest in pollution prevention. EA can be used

to bolster the economic argument and identify the facility's "true cost of quality." The

key to realizing the value-added of EA in electroplating is to link this tool with materials

balancing and materials accounting. The opportunity costs of wasted raw materials and

materials losses in electroplating are not only the most significant costs to consider, they

are the linchpin in understanding the reasons for the facilities environmental management

cost structures.
46

Calculating Value of Process Solutions and Lost Process Solution

Step 1 -- Determine total annual cost of material inputs

Step 2 -- Determine list of material inputs that individually are responsible for at least

5% of the total material input costs

Step 3 -- Determine value of individual process solutions on annual basis and in cost

per liter of solution. Start with electroplating solutions, then do acids and

cleaners. Occasional use solutions (strippers; chromates; other special-use

surface treatments) are optional at this time -- focus on "big tickets" first)

--Step 3a Determine "formula" for each process solution

 --List of constituents

 --Concentration of each constituent

 --Step 3b Determine cost of each constituent

--Step 3c Calculate value of solution

Step 4 -- Rank process solutions by cost

Step 5 -- Choose top-ranked electroplating process solution. Determine total metal

purchased for that solution as kg/year. Assure that all sources are

accounted for. For example, nickel metal in an electroplating process

solution is derived from, at a minimum:

• solid nickel anodes

• nickel sulfate solution

 and may have other sources.

Step 6 -- Determine total metal plated from that solution as kg/year. This is done by

determining total square decimeters of product processed through the

solution, and multiplying by the average thickness of the plated coating.

Convert to kg using weight to thickness tables.

Step 7 -- Subtract total in Step 6 from total in Step 5. Difference is metal lost to

dragout, although recognize that incorrect data can skew the analysis

Step 8 -- Repeat Steps 5-7 as necessary until 80% of costs due to purchase of

electroplating process materials has been analyzed
47

 Full EA Costing of Rejects

Step 1 -- Determine list of most common reject situations

Step 2 -- Describe actions taken to correct rejects, starting with most common cause or

 problem

 • Inspect

 • Sort and re-plate only bad parts

 • Strip and re-plate all parts

 • Purchase new parts and plate

Step 3 -- Determine cost of each action

 • Cost to detect rejects (inspection; return from customer)

 • Cost to correct reject (purchase new parts; strip and re-plate parts; spot

 re-plating

 • Cost of lost production time (rejected parts took the place of parts that

 could have been sold to generate income)

 • Cost of treatment and disposal of materials associated with corrective

 action

 • Overhead costs associated with corrective action

Step 4 -- Repeat Steps 1-3 until 80% of reject volume has been analyzed
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